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4 - Immediate solution (I) 10 No conformitiesImprovement ActionImplications Basic characterization analysis clinical waste (RBS) Presented a suitability certificate of analytical operations proposed in standards used for this kind of waste Increase in the current number of records and work procedures Temporary storage area for no admissible waste Justified the refuse of non admissible waste according to procedure describe in NC 1 Increase in controls Clinic waste piling above 2 levels According to containers homologation, they can be piled due to piling, resistance and sealing tests Continue with the same working practice (no implication) Clinic waste labeling Improvements in the HW signalingSlight improvement in the work procedure. HW area adaptation 8 9 12 13 12 13

11
4 - Immediate solution (II) 11 No conformitiesImprovement ActionImplications Neither segregation nor storage of WEEE Studied commonly with IMS WEEE the option of sending material. The option is rejected due to the bad condition of the waste Stored and sent just the potentially reused material (< 10 t/y) Leachate collection wells in closed and active landfill bodies The first leachate accumulation is detected in 2011. Installed a pneumatic system in order to pump it out Continue with the same working procedure. NO IMPLICATION Untreated clinic and HW leachate and cleaning water Analyzed waste water and discharged to public sewage system is considered Continue with the same working procedure. NO IPMLICATION 22 23 15 22

12
4 - Clarification required (I) 12 No conformitiesImprovement ActionImplications Clinical Waste (RBS) admission procedure Development of an specific procedure for the clinic waste admission and acceptance Increase in controls Documented Environmental Impacts control plan Adapted the existing control plan to the IPPC EIA requirements Increase in controls Risk assessment for MA by ECCM Presented Risk Evaluation to the ECCMA Increase in controls Maintenance and Cleaning Plan Developed a maintenance and cleaning program according to specifications Increase in current working procedure records 2 3 1 4

13
4 - Clarification required (II) 13 No conformitiesImprovement ActionImplications Editing of landfill incidents book Incident book is edited, including use instructions and custody responsible Increase in controls Open containers of Hazardous Waste General improvement of the loading area; adapting tanks, and properly signaling and labeling Increase in controls Hazardous waste labeling Hazardous Waste area signaling Used oil storage without dike There is neither specific HW loading area, nor draining in the HW storing area 16 17 14 18 19 20 16-20

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4 - Clarification required (III) 14 No conformitiesImprovement ActionImplications Meteorological data recording Created a record with meteorological parameters obtained from the closest National Network of Meteorological Stations Increase control and records Leachate analytics parameters Increase of numbers of characterized parameters Increase controls and records Autoclave monitoring results report Report with the result of parameters monitoring control in the autoclave (P, T, time) sent yearly to Environmental Authority Increase in controls and records 27 28 25/26 28 25 9 kms

15
4 - Clarification required (IV) 15 No conformitiesImprovement ActionImplications Report of landfilled waste with no previous treatment Yearly report recording waste landfilled no previous treatment Increase in controls Summary of 2007 Control Plan Report with results of sanitary data control to be sent to Environmental Authority Increase in controls 30 29

16
4 - Solution beyond Aborgase (I) 16 No conformitiesActionsImplications Recovery of potentially recoverable fractions Designed a plant for bulky waste treatment Presented to local association a cost assessment in order to increase tipping fee Constructed the first phase of the bulky waste treatment plant No increase in tipping fee Previous treatment of green waste, landfilling treatment procedure during technical shutdowns and weekends Designed a bulky waste treatment plant Desigend a revamping of MSW recycling plant, with 5 authomatized sorting lines, aimed at increasing capacit up to maximum Constructed the first phase of the bulky waste treatment plant After several modifications, increase manual sorting lines and optimized feeding and organic fraction refining processes Landfilling of potentially recoverable fractions 6 7 5 5

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4 - Solution beyond Aborgase (II) 17 No conformitiesActionsImplications Open air storage of recovered fractions, including compost Cost study of covering the area carried out Proposed by ABORGASE, expanded plastic treatment warehouse No coverage in the rest of storage areas Green waste is neither ground nor composted Designed a Bulky Waste treatment plant, with a front grinder for green waste (previous to composting) Grinder in included in second phase, which was not finally accomplished Compost and recovered fraction open air storage Carried out cost assessment of covering all the required areas Proposed by ABORGASE, expanded plastic treatment warehouse No coverage in the rest of storage areas 11 24 10 2410

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21 Conclusions – IPPC Implementation  The whole certification process has taken 6 years, being still alive  The certification was completed successfully, being granted in October 2007, and extended in July 2009  Out of a total 165 issues, just 30 were no conform  7 were of immediate solution  17 required discussion to really understand the situation and agree a feasible solution  In 6 the solution exceeded ABORGASE scope, 3 were solved by means of extra investment and in 2, were partially solved in agreement with the administration  The implementation process, moreover 6 years of work, has implied additional investments (9,4 M€), higher operation costs (+12%) and high increase in number of controls and records  The additional cost (investment and operation) are partially covered by ABORGASE  The IPPC has been a high challenge, but today we do a more responsible and respectful waste management activity

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